Legal Opinion

Chevy Chase Land Co. v. Commissioner

United States Tax Court

Decided June 12, 1979No. Docket No. 9875-77Published

Held, upon the facts of this case, a landowner's costs of negotiating a prospective long-term lease of an unimproved tract of land and the costs (except for one item) of an unsuccessful attempt to have the land rezoned are deductible as an abandonment loss, upon termination of the lease transaction, which was contingent upon obtaining the rezoning.

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Held, upon the facts of this case, a landowner's costs of negotiating a prospective long-term lease of an unimproved tract of land and the costs (except for one item) of an unsuccessful attempt to have the land rezoned are deductible as an abandonment loss, upon termination of the lease transaction, which was contingent upon obtaining the rezoning. Sec. 165(a), I.R.C. 1954. Held, further, one of the component items of the rezoning effort, the cost of a topographical map of the land, may not be included as part of the abandonment loss, since it had continuing value as a useful asset in the…

1Opinion of the Court

Chevy Chase Land Company of Montgomery County, Maryland, Petitioner v. Commissioner of Internal Revenue, Respondent

Chevy Chase Land Co. v. Commissioner

Docket No. 9875-77

United States Tax Court

72 T.C. 481; 1979 U.S. Tax Ct. LEXIS 103;

June 12, 1979, Filed

Decision will be entered under Rule 155.

Held, upon the facts of this case, a landowner's costs of negotiating a prospective long-term lease of an unimproved tract of land and the costs (except for one item) of an unsuccessful attempt to have the land rezoned are deductible as an abandonment loss, upon termination of the lease transaction, which…

2Cases cited10 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
  3. Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
  4. Edward R. Godfrey and Georgia G. Godfrey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
  5. Galt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954

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